The content in this course applies only to bridges that are 20 feet or longer, otherwise refer to the IS-1011 Roads and Culverts course. This is because any bridge less than 20 feet long is basically a road.

The type of technical expertise required to repair, replace, or rebuild bridges are FEMA Specialized Engineers. Throughout bridge projects, the role of the FEMA technical experts or specialized engineers are to perform damage assessments, prepare scope of work, and evaluate pre-existing condition of the bridge for compliance with safety standards.

The incident may cause minor damage to bridges or roads similar to that which may occur over time from other causes, such as the age of the bridge, traffic flow, and frequent rain. Therefore, distinguishing between pre-existing damage and damage caused by the incident is often difficult.

For the repair of this type of damage to be eligible, the Applicant must demonstrate that the damage was directly caused by the incident. The impact of the damage to the bridge's capacity and function should also be documented.

Public Assistance funding is always based on pre-disaster size, capacity, and function. For Permanent Work, documentation is needed supporting pre-disaster condition of the facility.

For bridges over 20 feet, a bridge report must be completed to document pre-disaster condition. This should occur at least once every two years according to the Federal Highway Administration. 

As well as reviewing the completed bridge report to verify the pre-disaster condition, perform structural inventory and appraisal for the bridge. This should include comments and the most recent photograph of the bridge.

In addition to bridge reports, the following documents are useful for assessing the pre-disaster condition of a bridge: structural inventories, appraisals, recent pre-disaster photographs, the most recent underwater inspection, a Scour Plan of Action (if applicable), and maintenance and protection efforts.

Pre-disaster design means the size or capacity of a facility as originally constructed or subsequently modified.

Pre-disaster design can be determined using as-built drawings, structural assessments, fracture-critical member reports, and load rating reports. Structural assessments usually occur every five to ten years.

Careful documentation of inspection findings is mandatory. The documented findings are useful for planning appropriate inspection cycles, evaluating the amount of deterioration that has occurred between inspections, and determining maintenance requirements. Sites of significant findings must be carefully identified to enable divers to return to the same location for further assessment. Documentation can take the form of detailed written reports, sketches, and measurements.

Pre-disaster function is the function the facility was performing immediately prior to the disaster. It is the function for which the facility was originally designed or subsequently modified.

If a facility was serving an alternate function at the time of the incident, but was not altered to provide that function, FEMA provides Public Assistance funding to restore the facility either to the original pre-disaster function, or pre-disaster alternate function, whichever costs less.

Codes and standards must be appropriate to the pre-disaster use of the facility. Bridge standards are set by the American Association of State Highway Transportation Officials. FEMA determines the eligibility of code required upgrades based on the facility's pre-disaster design or actual use at the time of the disaster. The least costly of the following is eligible:

• Pre-disaster use of the facility, if serving the same function for which it was originally designed; or
• Alternate use of the facility, if serving an alternate function at the time of the incident.

The following example is a code or standard that is not appropriate to the pre-disaster use of the facility.

A Bridge in Hazard City was washed out during a flash flood. The bridge was in active use at the time of the event. The bridge was a single lane wooden bridge. The applicant has requested to replace the bridge with a two-lane wooden bridge in accordance with their Codes and Standards.

To document Codes and Standards, the Applicant was required to document compliance with the five Codes and standards criteria in accordance with FEMA Public Assistance Program and Policy Guide.

Through the documentation request, the Applicant was unable to show that they formally adopted resolution that all single lane bridges be replaced with two-lane bridges and they could not document the work as a uniform practice.

As a result, the Applicant is unable to claim codes and standards as a scope and cost method for repair and the FEMA Public Assistance program is only able to support costs for replacement to pre-disaster condition.

The Applicant has two options moving forward:

1. Replace the bridge to its pre-disaster condition.
2. Prior to initializing work, the Applicant may request an improved project. The project cost is capped at the cost to replace to pre-disaster condition (single lane wooden bridge) and the Applicant must fund the additional costs to cover the improvements above and beyond the pre-disaster design and capacity (two-lane wooden bridge).

To request an improved project, the Applicant must submit formal written request to the Recipient defining the nature and design of the improvement. If the Recipient is in concurrence, the request is forwarded to FEMA for approval.

Improved projects are addressed through FEMA Public Assistance Program and Policy Guide.

The Applicant is required to identify and report all its disaster-related damage, Emergency Work activities, and debris quantities to FEMA within 60 days of the Recovery Scoping Meeting. FEMA may extend the deadline for identifying and reporting damage if the Recipient submits a request in writing with justification based on extenuating circumstances beyond the Recipient's or Applicant's control. For example, if a site is inaccessible, FEMA may extend the deadline for that site.

FEMA conducts site inspections with the Applicant to validate, quantify, and document the cause, location, and details of the reported damage and debris impacts and identify environmental and historic preservation issues and hazard mitigation opportunities within this 60-day period.

FEMA, the Recipient, and the Applicant should reach an agreement on the disaster-related damage description and dimensions, Emergency Protective Measures, and debris impacts before proceeding with scope of work development.

For Emergency Work, FEMA may request:

• Description of the immediate threat
• Record demonstrating presence of the immediate threat (e.g., technical reports, safety inspector reports, photographs)

Additionally, for debris specifically:

• Actual debris quantities by type
• For waterway debris, documentation supporting pre- and post-incident levels, such as waterway surroundings

The following is documentation that supports immediate threats, debris impacts, or damage for Permanent Work that FEMA may request:

• Drawings, sketches, and plans (to scale) of disaster-related damage
• Photographs of site, overall facility, and specific damage
• Detailed description of damage with specific dimensions
• Plans and specifications showing pre-disaster design of the facility
• Documentation supporting pre-disaster condition of facility (e.g., facility maintenance records, inspection/ safety reports)

FEMA may approve changes to the pre-disaster design or construction method (including materials) if the changes are required due to:

• Access issues
• Site conditions, or
• To tie in to existing infrastructure

The changes must not impact the capacity or function of the facility.

The Applicant must show that the changes are reasonable based on the type and extent of restoration and are consistent with the Applicant's general construction practices.

The following is an example of restoring a bridge to pre-disaster design.

A Bridge in Hazard City was washed out during a flash flood. The bridge was in active use at the time of the event. The bridge was a single lane wooden bridge. The applicant has requested to replace the bridge with a concrete pier and deck bridge.

The bridge design is not the same as the pre-existing condition.

The Applicant has three options moving forward:

1. Replace the bridge to its pre-disaster condition.
2. Prior to initializing work, the Sub-recipient could propose and request Hazard Mitigation grants opportunities as defined in FEMA Public Assistance Program and Policy Guide, January 2018, Page 99-101.
3. Prior to initializing work, the Applicant may request an improved project. The project cost is capped at the cost to replace to pre-disaster condition (single lane wooden bridge) and the Applicant must fund the additional costs to cover the improvements above and beyond the pre-disaster design and capacity (concrete pier and deck bridge).

Applicants can also utilize Public Assistance Alternative Procedures for Permanent Work to have a capped grant that may cover the proposed bridge. See Independent Study course IS-1005 Public Assistance Alternative Procedures for more information.

To request an improved project, the Sub-recipient must submit formal written request to the recipient defining the nature and design of the improvement. If the recipient is in concurrence, the request is forwarded to FEMA for approval. Reference FEMA Public Assistance Program and Policy Guide.

When evaluating eligibility of reported damage, in addition to evaluating how the incident caused the damage, FEMA reviews maintenance records or documentation establishing that the Applicant has a routine maintenance program.

In the absence of maintenance records, FEMA reviews material purchase invoices, activity logs, and inspects other sections of the Applicant's road system to confirm the performance of normal maintenance activities.

Normal maintenance is not eligible. Work to repair potholes or fatigue cracking is generally ineligible as this type of damage is rarely caused directly by one incident.

A written maintenance plan and/or activity logs should be kept to document regular intervals of activity. Applicant logs documenting clearance of blockages in response to resident complaints are not sufficient to substantiate a regular maintenance schedule.

The Applicant needs to make every effort to afford FEMA the opportunity to perform Environmental and Historic Preservation reviews prior to the start of construction for any Permanent Work project.

Proceeding with Permanent Work before FEMA completes Environmental and Historic Preservation reviews jeopardizes Public Assistance funding.

When Environmental and Historic Preservation laws, regulations, or Executive Orders require actions to mitigate adverse effects, the Applicant is responsible for all costs associated with performing the required mitigation measures, unless such actions are directly related to the restoration of disaster-related damage.

If required by a code or standard FEMA may fund upgrades.

All Codes and Standards must meet FEMA's five criteria standards:

• Applies to the type of restoration required;
• Is appropriate to the pre-disaster use of the facility;
• Is reasonable, in writing, formally adopted by the State, Territorial, Tribal, or local government, and implemented by the Applicant on or before the declaration date, OR is a legal Federal requirement;
• Applies uniformly; and
• Was enforced during the time it was in effect

When rebuilding to American Association of State Highway Transportation Officials or State Department of Transportation standards, it is not automatically considered an eligible code and standard, and using these standards may be considered an improved/alternate project.

For more information about Codes and Standards, see the Independent Study course IS-1019 Codes and Standards.

Codes and Standards must apply to the type of restoration required. Codes and standards for new construction are often different than codes and standards for repair work. The triggers should clearly differentiate between repair and new construction.

If FEMA determines a facility is eligible for replacement, compliance with current codes and standards for new construction is eligible. If FEMA determines a facility is not eligible for replacement, only code-required upgrades applicable to repair are eligible.

A code or standard may include a trigger that requires:

• Upgrades to all structural components; or
• In addition to upgrading all structural components, bringing the non-structural components into conformance with current codes or standards for new construction.

In cases where ineligible damages, such as a pre-existing condition, if not repaired, may compromise repair of eligible damage, FEMA may make Public Assistance funding for repair of the eligible damage contingent upon the Applicant repairing the ineligible damage.

FEMA may determine that repairs to a damaged bridge deck are eligible. However, the deck cannot be repaired unless the Applicant replaces rotting timbers that support the deck.

To determine if a facility is eligible for repair costs or replacement costs FEMA uses the 50% rule. The 50% rule is a calculation to compare the eligible repair cost to the eligible replacement cost results in a fraction that expresses repair as a percentage of replacement. The percentage is calculated with the repair cost as the numerator and replacement costs as the denominator. FEMA refers to this calculation as the "50% Rule".

Bridges are examples of facilities of which FEMA applies the 50% Rule to the entire facility.

An Improved Project is a project that restores the pre-disaster function, and at least the same capacity, of the damaged facility and incorporates improvements or changes to its pre-disaster design that is not required by eligible codes or standards.

For Improved Projects, the Applicant must obtain approval from the Recipient. If the Improved Project significantly changes the pre-disaster configuration of the facility, the Recipient must forward the request to FEMA to ensure that the Improved Project complies with appropriate Environmental and Historic Preservation laws, regulations, and Executive Orders.

An Alternate Project is the use of funds toward a project that does not restore the pre-disaster function of the damaged facility. If the Applicant determines the public welfare would not be best served by restoring a damaged facility or its function, it may use the funds toward a different facility (or facilities) that benefit the same community.

Federal funding for an Improved Project is limited to the lesser of the following:

• The Federal share of the approved estimated cost to restore the damaged facility to its pre-disaster design and function; or
• The Federal share of the actual costs of completing the Improved Project.

FEMA only increases eligible funding for an Improved Project if the Applicant identifies an error or omission in the original scope of work or cost estimate related to restoring the facility to its pre-disaster design and function.

If a Federal, State, Territorial, Tribal, or local government permitting agency requires additional work based on a code or standard that does not meet eligibility criteria, then the cost of the additional work is only eligible if the work:

• Applies to the type of restoration required;
• Is appropriate to the pre-disaster use of the facility;
• Is reasonable, in writing, formally adopted by the State, Territorial, Tribal or local government, and implemented by the Applicant on or before the declaration date OR is a legal Federal requirement;
• Applies uniformly; and
• Was enforced during the time it was in effect.

Mitigation measures must be reasonable. When determining reasonableness, FEMA:

• Examines the general reasonableness of the code and standard and the trigger for application of the code or standard;
• Determines whether the upgrade and trigger relate to the type of restoration required by the damage and whether the upgrade and trigger are justified based on the extent of the damage;
• Considers whether the upgrade and the trigger are technically defensible from an engineering perspective; and
• Determines whether the cost of the upgrade is reasonable.

FEMA may determine a very large upgrade based on a very low trigger to be unreasonable.

Mitigation measures must be cost-effective. FEMA considers mitigation measures to be cost-effective if any of the following criteria are met:

• The cost for the mitigation measure is within 15% of the total eligible repair cost (prior to any insurance reductions) of the facility or facilities for which the mitigation measure applies
• The mitigation measure is specifically listed in Public Assistance Program and Policy Guide Appendix J: Cost-Effective Hazard Mitigation Measures, AND the cost of the mitigation measures does not exceed 100% of the eligible repair cost (prior to any insurance reductions) of the facility or facilities for which the mitigation measure applies
• The Recipient or Applicant demonstration through an acceptable benefit-cost analysis methodology that the measure is cost-effective. FEMA's benefit-cost analysis software provides appropriate benefit-cost analysis methodologies

A Benefit-Cost Analysis is based on a comparison of the total eligible cost for the mitigation measure to the total value of expected benefits. Benefits include reductions in:

• Damage to the facility and its contents
• The need for emergency protective measures
• The need for temporary facilities
• Loss of function
• Casualties (typically included only for earthquake, tornado, and wildlife mitigation)

Permanent Work to restore bridges is eligible unless restoration is under the specific authority of another Federal Agency such as the Federal Highway Administration.

Work to repair scour or erosion damage to a channel or stream bank is eligible if the repair is necessary to restore the structural integrity of an eligible road, culvert, or bridge.

Hydrologic and hydraulic studies, used to evaluate upstream and downstream impacts, may be necessary if replacing culverts or bridges with larger culverts or bridges.

Applicants that receive Public Assistance funding for Permanent Work to replace, repair, reconstruct, or construct a facility must obtain and maintain insurance to protect the facility against future loss.

If the Applicant does not maintain the required insurance from a previous disaster, then the facility is not eligible for Public Assistance funding in a subsequent disaster, regardless of the hazard(s) that caused the damage.

When the Applicant receives Public Assistance funding for a facility damaged by the same hazard in a subsequent disaster, FEMA reduces funding in this subsequent disaster by the amount of insurance required from the previous disaster.

If FEMA or the State Insurance Commissioner certification modified the Applicant's insurance requirement, FEMA reduces funding by the modified insurance amount. If the Applicant's anticipated or actual insurance proceeds are higher than the amount of insurance required in the previous disaster, FEMA reduces funding by the anticipated or actual amount of insurance proceeds to avoid a duplication of benefits.

Funding duplication issues can stem through other aid programs like:

• National Resource Conservation Service
• Federal Highway Administration (BRO funds)
• Bureau of Indian Affairs funds

The Federal Highway Administration has authority to assist with the restoration of transportation facilities under the Emergency Relief for Federally Owned Roads Program.

FEMA is legally prohibited from duplicating benefits from other sources. If the Applicant receives funding from another source for the same work that FEMA funded, FEMA reduces eligible cost or de-obligates funding to prevent a duplication of benefits.